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2013-01-29_REVISION - C1981008
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2013-01-29_REVISION - C1981008
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Entry Properties
Last modified
8/24/2016 5:12:31 PM
Creation date
2/20/2014 7:55:50 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
Revision
Doc Date
1/29/2013
Doc Name
Paintiffs Opening Brief 2010 CV 548
From
Christopher G. McAnany Dufford, Waldeck, Milburn & Krohn, LLP
To
District Court, Montrose County Colorado
Type & Sequence
PR6
Email Name
DAB
Media Type
D
Archive
No
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permit encompassing prime farmlands is reviewed for decision, DRMS is required <br />to determine whether the: <br />"operator has the technological capability to restore such mined area, within <br />a reasonable time, to equivalent or higher levels of yield as nonmined prime <br />farmland in the surrounding area under equivalent levels of management and <br />that the operator can meet the soil reconstruction standards in section 34-33 - <br />120(2)(g)." C.R.S. § 34- 33- 114(4)(a). <br />Thus, the threshold determination of the presence of prime farmlands within a <br />mine permit area triggers a host of procedural and technical review steps for the <br />agency, and results in specific operational and performance standards being <br />imposed on the operator. The failure to correctly identify prime farmlands prior to <br />mining short circuits these important steps designed to protect crop lands. DRMS <br />regulations under SCMRA mandate that an applicant "shall conduct a <br />preapplication investigation of the proposed permit area ... to determine whether <br />lands within the area may be prime farmland." Rule 2.04.12. The rule requires <br />that an applicant rule out the presence of prime farmland based upon the presence <br />of a number of disqualifying criteria, including a determination that, on the basis of <br />a soil survey, there are "no soil map units" designated as prime farmland by the <br />U.S. Soil Conservation Service (now NRCS) within the permit area. Id. at (2)(f). <br />If the soil survey shows areas which "may be prime farmland historically used for <br />17 <br />
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